Published: 2/20/2022 8:09:47 PM
Modified: 2/20/2022 8:09:27 PM
I was relieved to see the article titled “Lunt property under audit by Mass DEP” in the Saturday, Feb. 12 edition of the Recorder. I’ve been concerned about mismanagement at the 298 Federal St. site and was grateful to hear that others in the community were sharing these same concerns. I was delighted to see that some citizens have even gone as far as contacting the MassDEP’s audit section chief, John Ziegler, which in turn triggered the opening of an investigation. An audit is not a “normal part of the (PIP) process” as stated by the mayor in that article. It is something that needs to be requested, or is brought about by the MassDEP if enough concerns are voiced.
So why is an audit so desperately needed? It’s because those we hired to be in charge of the cleanup did not do their job. Michael Hootstein, the principal hydro geologist of the Legacy Environmental Group,volunteered his time to look into the cleanup activities in an effort to understand why we are in the situation we are now. He wrote a very detailed report citing all the ways that O’Reilly, Talbot and Okun (OTO) allegedly violated 310 CMR 40.0000 regulations of the Massachusetts Contingency Plan (MCP), leaving people in harm’s way, and the city open to lawsuits. The 14-page report shows serious deficiencies in the investigation, characterization and clean-up efforts at the Lunt property.
OTO has failed us. They failed us by allowing the premature redevelopment of the property before containment controls were in place. They failed us by allowing patients and staff members to occupy the residential detox and rehabilitation facility before it was certain that air quality tests were within normal limits. It wasn’t until a week after the facility opened that testing was done. Trichloroethylene levels came back so high that a two-hour immediate response action was required per the U.S. EPA because of “imminent hazardous conditions”. They failed us by not installing a groundwater collection and treatment system as they said they would. It would have isolated the contaminates, to keep the released materials from further spreading, and contributing to public exposure by way of groundwater and vapor intrusion into indoor air. They failed us by not following through with the project.
In general, a site like the Lunt property should be fully remediated within a 6-year time frame, and yet it’s been over 10 years from the initial Phase II report. Both a phase III and a Phase IV report should have already been filed. Interestingly enough, activity wasn’t resumed until after the question of whether the site was clean or not came up in October 2021. It was December 1, 2021, when OTO filed for a 6-month extension to present MassDEP with a Phase III report. They mislead us by having us believe that the documents filed with the MassDEP were a sort of ‘certificate’ on what was being done and that it was accurate and correct. In her letter to Glen Ayers, Elizabeth Stinehart, the deputy regional director of the Bureau of Waste Site Cleanup states, “The cleanup of contaminated sites in MA is a privatized program that requires the Licensed Site Professionals (LSP) to evaluate and oversee the remediation”. The MassDEP does not provide direct oversight of remediation efforts, they rely on the veracity or truthfulness of the LSP professionals. OTO did a sub-standard job, then reported that everything was up to par, which was clearly not the case.
I have listed a few of the many reasons why an audit is necessary. Michael Hootstein offered 11 much more detailed deficiencies in the work submitted to the MassDEP by OTO. In his conclusion, he writes, “a full audit of the Lunt property contamination investigation, cleanup and compliance with the Massachusetts MCP regulations, 310 CMR 40.0000, is urgently needed today: 1) to determine how this process went so far off the rails; and 2) what steps will be necessary to gain control of the remaining site contamination so as to mitigate ongoing threats to public health and bring the cleanup into compliance with the MCP”.
In my opinion, not only do we need an audit, but O’Reilly, Talbot and Okun must be replaced with a remediation company that will abide by the rules and standards set forth by the MassDEP. This is too important an issue. We need to take a stand in order to make sure our neighbors are safe. I urge you to contact the City Council by phone at 413-772-1555 x6163 or by email at [email protected].
Stephanie Duclos lives in Greenfield.